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Pennsylvania Health Insurance Exchange Authority
Pennsylvania Health Insurance Exchange Authority – Board of Directors MeetingFebruary 19, 2020
Meeting Agenda
1. Preliminary Matters
2. Standard Administrative Updates
3. Standard Technology and Operations Update
4. Branding Update
5. Update from Chini Krishnan of GetInsured
6. Review and Discussion of the 2021 Plan Certification Requirements and Process
7. Notice of Benefit and Payment Parameters
8. Presentation of the Employee Handbook
9. Adjourn
Exchange Authority | 2
Pennsylvania Health Insurance Exchange Authority
Preliminary Matters
3
Pennsylvania Health Insurance Exchange Authority
Administrative Updates
4
Updates
▪ Personnel
▪ Stakeholder Engagement
▪ Brokers
▪ Insurers
▪ Advocates
▪ Advisory Council
▪ State-Based Exchange partners
Administrative Updates
Exchange Authority | 5
▪ Insurance Agents & Brokers roundtable meeting
▪ Introduced the Exchange Authority
▪ Discussed transition approach
▪ Policy process, including stakeholder feedback.
▪ Offered to create a broker question form to receive questions and feedback
▪ Briefed on plan certification proposed policy
▪ Broker certification policy – TBD
▪ Broker data migration from the Federally Facilitated Marketplace
▪ Limited data from FFM, need to work with PID and broker community to try to fill in gaps
▪ Complete broker data required to successfully migrate brokers
Stakeholder Engagement
Brokers
Exchange Authority | 6
▪ EDI Technical Working Group (weekly)
▪ Setting up Connectivity
▪ Addressing technical questions after insurer review of EDI technical documentation
▪ Pay Now payment redirect schema discussed
▪ Insurer Policy Working Group (bi-weekly)
▪ Introduced a variety of policies, including plan certification proposals,
▪ 2 weeks for carriers to provide feedback via webform
▪ Late addition for feedback was no APTCc on zero dollar renewals
▪ Service Coordination Working Group
▪ TBD
▪ Information Sharing
▪ SharePoint site live
▪ Carriers updating contact list to get access to SharePoint
▪ Comprehensive question and answer log available
▪ Recordings of working group meetings will be available on SharePoint
Stakeholder Engagement
Insurers
Exchange Authority | 7
▪ Advocates
▪ Exchange Assister After Action Review conducted (2/14)
▪ Scheduled an initial meeting with the PA Coalition for Oral Health (2/21)
▪ Worked with Advancing Strategies to Align Programs to develop a list of 20+ statewide community
groups. Will engage these partners via a Working Group for ongoing feedback
▪ Advisory Council
▪ First meeting 2/7, all but legislative appointees in attendance
▪ Established the mission of the Council -- to provide a forum for input and discussion of issues important
to improving the accessibility and affordability of individual market health coverage for Pennsylvanians.
▪ Assessing the feasibility of the Council’s recommendation to meet 3+ times during year one
▪ Meeting topics included: Exchange overview, governance, plan certification, pending tech/ops/policy
decisions, the Exchange Assister program
▪ Other State-Based Exchanges
▪ Meeting regularly with Nevada and New Jersey
▪ Actively sharing documents with New Jersey
Stakeholder Engagement
Advocates, Advisory Council, and Others
Exchange Authority | 8
Pennsylvania Health Insurance Exchange Authority
Standard Technology and Operations Update
9
Agenda
▪ Stars on a String Status Report
▪ System Requirements and Design Process
Standard Technology and Operations Update
Exchange Authority | 10
▪ Requirements Finalization Will Involve Integration of Information From Multiple Sources:
▪ Identified Items From PA Exchange Authority and UAT Team Review of System and Preliminary Sizing
▪ Items From GetInsured’s Product Development Roadmap for 2020
▪ Priority Items From the NJ Exchange Authorities Review of the System
Note: several categories of final requirements will still be open, including: screen text, notice language and
content, & system color schemes and branding.
▪ Integration and Draft Finalization Is Targeted for End of This Month
▪ Team Will Align Priorities Internally Prior to Reviewing with GetInsured
▪ Team Will Agree With GetInsured Which Items Are Regulatory and Must-Haves
▪ Team Will Work With GetInsured to Confirm Priority Delivery Items
▪ Team Will Subsequently Craft Delivery / Release Plan With GetInsured to Deliver Identified Priority
Items
▪ Lastly, Joint Team Will Determine Method of Preserving Remaining Requirements for Review in
Subsequent Year Prioritizations
System Requirements and Design Process
Exchange Authority | 12
Decision Policy Goal(s) Benefits Challenges
Default APTC
Percentage
(On Initial
Application)
Provide best customer
experience possible
• Setting value at less than
100% could lessen
chances that customers
have to pay more in
taxes at the end of the
year
• Presenting customers plans that cost
more (if less than 100% APTC is
applied) could discourage some
purchases
• Could be significant need for technology
work to implement not only default
changes, but shopping flow changes
Exchange Authority | 13
Informational Decisions
▪ Summary of Stakeholder Feedback:
▪ Broad stakeholder support for the need to focus on educating customers about the need to estimate
their income as accurately as possible, timely report any changes to income, and talk to their tax
advisor to understand potential tax implications.
▪ Potential tax consequences outweighed the risk that initially showing plans with less than the
maximum available APTC might result in customers not enrolling or enrolling in a plan with more
cost sharing or lower AV than they wanted.
▪ Staff Decision:
▪ Default to 100% of maximum APTC
▪ Focus on communications to remind customers of potential tax consequences of taking more APTC
than eligible, need to report changes to projected income, etc.
Decision Policy Goal(s) Benefits Challenges
Default APTC
Percentage
(At Auto-Renewal)?
Provide best customer
experience possible
• Setting value at less than
100% could lessen
chances that customers
have to pay more in
taxes at the end of the
year
• Presenting customers plans that cost
more (if less than 100% APTC is
applied) could discourage some
purchases
• Could be significant need for technology
work to implement not only default
changes, but shopping flow changes
Exchange Authority | 14
Informational Decisions
▪ Summary of Stakeholder Feedback:
▪ Stakeholder feedback was mixed. Stakeholders generally supported trying to apply the same APTC
to autorenewal policies whenever possible, while also recognizing that premiums and 2nd lowest cost
silver plan change year over year so it’s not a perfect comparison.
▪ Staff Decision:
▪ Pursue feasibility of applying prior year’s APTC percentage to autorenewal policy (would require IT
changes).
▪ Focus on communications to remind customers of potential tax consequences of taking more APTC
than eligible, need to report changes to projected income, and review their autorenewal policy each
year at OEP.
Decision Policy Goal(s) Benefits Challenges
Two-Factor
Authentication for
Brokers & Assisters
(e.g. Navigators,
CACs)?
Secure customer
information without
causing undue
operational burden on
community partners
• Provides extra layer of
security for customer
information for those
customers working with
brokers and assisters
• May make operational process slightly
more challenging for these partner users
Exchange Authority | 15
Informational Decisions
▪ Summary of Stakeholder Feedback:
▪ Brokers and assisters supported this requirement, with no operational concerns. Some confirmed
that this is their current process.
▪ Broad support from stakeholders to require additional levels of security for users with access to other
customer’s data.
▪ Staff Decision:
▪ Require two-factor authentication for brokers & assisters
Pennsylvania Health Insurance Exchange Authority
Branding Update
16
Exchange Authority | 17
Exchange Authority | 18
Exchange Authority | 19
SHADAC analysis of the United States Census Bureau's American Community Survey (ACS).
Exchange Authority | 20
Exchange Authority | 21
Exchange Authority | 22
Exchange Authority | 23
Exchange Authority | 24
Exchange Authority | 25
Exchange Authority | 26
Pennsylvania Health Insurance Exchange Authority
Update from Chini Krishnan of GetInsured
27
© Copyright GetInsured 2020 28
January 16-17
Call Center Kickoff
February 19, 2020
Board Meeting
PENNSYLVANIA
© Copyright GetInsured 2020 29
Agenda
Topic
About GetInsured
Key Focus Areas for the Commonwealth
Call Center Update
Closing Q&A
© Copyright GetInsured 2020 30
Founded in 2005
Deep roots for more than 12 years in Atlanta,
Georgia and Mountain View, California
Public Sector Cloud Transitions
We are the leading technology provider for
states transitioning off of healthcare.gov to
state-based marketplace solutions
500+ Employees
World-class engineering and healthcare talent
from Amazon, eBay, Google, Yahoo!
Market Leader
● Venture Backed -- Bessemer
● Dominant Market share
● Rapidly growing recurring revenue
● Consistently Profitable
● World-class Team
Introduction to GetInsured
Our mission is to deliver the best cloud-based solutions to states (and their partners -- carriers, brokers and consumers)
Enrollees serviced each year,
80% of all SBM enrollments
State-Based Marketplaces
leverage GetInsured technology
and/or customer service centers
8,000+agents using the
GetInsured platform
1,000health plans on the
GetInsured platform
2M 7
Footprint
Shankar Srinivasan
GM & Co-Founder
Shankar leads the company’s product
management function.
Chini Krishnan
CEO & Co-Founder
More than 20 years of experience in the
high technology industry
© Copyright GetInsured 2020 31
The Pennsylvania Project Leads
Dawn Hughan
DDI Manager
Richard Draper
Call Center Lead
Michael Daugherty
Call Center Director
Danielle Hubbard
Trainer/Facilitator
Pla
tfo
rm/P
rog
ram
Ma
na
ge
me
nt
Co
ns
um
er
As
sis
tan
ce
Cen
ter
John Arthur
Change Mgmt
Call Center Lead
Yannick Deville
Telephony Engineer
Ashley Hargrett
Senior Operations
Rajiv Chawla
Project Manager
Chini Krishnan
CEO
Shankar
Srinivasan
COO
Paul Neutz
SVP, Business
Development
Sephy Hambaz
Chief of Staff &
VP Operations
Marc
Cooperson
Director, PM of
Platform
© Copyright GetInsured 2020 32
1,000+ Plans
Our Customers
2005 - 2010 2010 2015 - present
We built the ‘Travelocity’
for health insurance prior
to the ACA. We made the platform easy to
use for brokers and agents. Our technical platform functions as an
“Exchange-in-a-Box” for states.
8,000 Brokers
Consumer MarketplaceBrokers & Agents State-Based
Marketplaces
2.5M+ Enrollments
© Copyright GetInsured 2020 33
JAN
PHIEA Roll Out - Key Focus Areas
DECNOVOCT
Connection to Federal Hub 9/1
CMS Approval and Authority to Connect 9/1
SEP
FFM Migration
FFM Catch Up
Data 12/17
AUGJULJUNMAYAPRMARFEB2020 JAN
Contact
Center
Lease
agreement
signed
Contact Center
Detailed project plan Contact Center
Facility move in
Contact Center
First class for CSRs
6/1 - 10/15
Contact Center
Infrastructure
Stand up
OEP
Begins
Contact Center
Operational 10/9
Broker
Training
9/17 - 10/26
2021 Plans
Loading
Data Migration
Starting 9/9
Platform Release 2
9/21
Insurer Testing
Complete 9/26
Platform Release 1 6/22
Auto-Renewals
10/12 - 10-16
Insurer Integration
Starts 2/14
Platform Requirements
Complete 3/6
Medicaid Integration
Complete 6/30
2021
Coverage
Begins
Platform
Release 3
1/4
Security
Platform
Insurers
Contact Center
Security Documentation
initiated
© Copyright GetInsured 2020 34
New Call Center Space Update
Cumberland Center
3065 Akers Mill Rd SE, Atlanta, GA 30339
● New lease signed on former Sprint Call
Center space
● Agreement signed with Nelson Architectural
Engineers
● RFPs out to General Contractors (GC) due
back Feb 21
● GC selection set on or before Feb 28
● Next phase SDs (Schematic Design) and DDs
(Design Development)
● June to July move-in date
● Sits on the most reliable power grid in Atlanta
● Existing backup high capacity generator
capable of powering entire building
Pennsylvania Health Insurance Exchange Authority
2021 Plan Certification Requirements and Process
35
Purpose
▪ Plan certification policy provides guidance to insurers regarding successful participation in
Pennsylvania’s exchange for 2021.
▪ Exchange as “active purchaser” - determine plans to be in the best interest of qualified individuals (45
CFR §155.1000(c)(2)).
▪ Plan certification requirements are in addition to compliance with federal and state rules.
Goals
▪ Access to high quality, comprehensive, affordable health coverage for Commonwealth residents
▪ Access to tools and resources to help customers make the best decision for their unique needs
Process
2021 Plan Certification
Exchange Authority | 36
Engage Stakeholders
Stakeholder Feedback & Staff Recommendations
Board Decision
Proposal Policy Goal(s) Benefits Challenges
Neither the Insurer nor any
subsidiary or affiliate of the
Insurer may offer short-term
limited duration (STLD) plans
in the individual market
within the Commonwealth for
the 2021 plan year.
Provide high quality,
affordable,
comprehensive health
coverage to
Commonwealth residents
• Ensure Commonwealth
residents have access to quality
comprehensive health coverage
• Prevent splitting individual
market risk pool, thereby
increasing costs of exchange
plans
• Would limit flexibility of
insurers offering
exchange coverage
from starting to offer
STLD plans (no
exchange insurers
currently offer STLD)
Exchange Authority | 37
▪ Summary of Stakeholder Feedback:
▪ Broad support across consumer groups, brokers, assisters, insurers, providers/health systems. Concerns included:
▪ STLD plans are confusing to customers, misleading them to think they have comprehensive coverage when they don’t
▪ Healthy individuals will be lured out of the individual market risk pool due to lower premiums of STLD plans, thereby
increasing costs for marketplace plans.
▪ 5 Insurers supported, 2 Insurers expressed concern about “wanting to maintain flexibility to offer this type of product
in the future depending upon market demands” and “unnecessarily segments the health insurance market by forcing
carriers to choose between participating on the SBE or participating in the STLDI market”
▪ 1 Insurer questioned whether this this restriction “falls outside of PHIEA scope of regulatory authority”
▪ 1 Insurer thought that the subsidiary/affiliate language was too broad and therefore overly restrictive.
▪ Staff Recommendation: Adopt requirement #1 as written
▪ STLD plans are confusing to consumers, are not comprehensive coverage, and adversely impact the individual
market risk pool which would increase costs to exchange coverage
2021 Plan Certification
Proposed Requirement #1
Proposal Policy Goal(s) Benefits Challenges
Opioid crisis
guidelines,
implemented by
Medicaid in March 2018
Commonwealth priorities
to address opioid crisis
• Ensures all plans have
comprehensive access to
coverage addressing opioid crisis
• New insurers to exchange would
be offering same coverage
current exchange insurers offer
• Risk of being considered a
new mandate with
unintended cost impact
Exchange Authority | 38
▪ Summary of Stakeholder Feedback:
▪ General support across consumer groups, brokers, assisters, insurers, providers/health systems. Support included:
▪ Importance of access to Medication Assisted Treatment (MAT) in addressing opioid crisis
▪ Protection that new entrants to marketplace will include coverage already provided by current insurers
▪ 1 Insurer requested clarification regarding specific drug formulary
▪ 1 Insurer expressed concerns about whether this could be interpreted to be a new mandate and therefore cost would
be responsibility of state, and questioned whether this restriction “falls outside of PHIEA scope of regulatory authority”
▪ Staff Recommendation: Withdraw Requirement #2 from 2021 Policy
▪ Risk of cost impact if this were to constitute a new mandate. Current draft federal rule may provide clarity or change
interpretation of this provision.
▪ Current exchange insurers already include this coverage so requirement not needed to ensure access at this time.
2021 Plan Certification
Proposed Requirement #2
Proposal Policy Goal(s) Benefits Challenges
Consistent Rate of
Producer/Broker
Commissions
Provide Commonwealth
residents with access to
licensed producer
services, including plan
recommendations
• Allows producers to plan
for participation in
exchange, including
staffing, sales strategy,
etc.
• Not current practice for most current
exchange insurers
Exchange Authority | 39
▪ Summary of Stakeholder Feedback:
▪ Support from some stakeholders (consumer groups, assisters, brokers).
▪ Brokers report that the lack of consistent commission schedules over the past years (including commissions being
reduced suddenly mid-year) has made it difficult for them to make time/resource investment to participate in exchange,
and sudden reduction/elimination of commissions has caused them significant disruption
▪ 2 Insurers reported that this was their current practice.
▪ Insurers (5 of 7) reported opposition as this would be a change to their current practice. Concerns included:
▪ inflexible, would "encroach into business decisions,” would lead to insurers removing commissions altogether,
▪ it doesn’t take into account the higher effort required for a new sale versus a renewal, and
▪ 1 Insurer noted that they would like to be able to pay lower commissions for SEP enrollments due to “higher overall
volatility, partial-year premiums, and some increased risk of fraud”
▪ Staff Recommendation: Withdraw Requirement #3 for 2021
▪ Customer access to a robust network of brokers is an important tool to support customer decision making.
▪ While we recognize that we don’t know what we don’t know, we see the value that consistent commission schedules brings to
ensuring broker participation. We plan to monitor in 2021 and reconsider for 2022 as appropriate.
2021 Plan Certification
Proposed Requirement #3
Proposal Policy Goal(s) Benefits Challenges
Advanced Notice of
Producer/Broker
Commission
Payment Schedule
Provide Commonwealth
residents with access to
licensed producer
services, including plan
recommendations
• Ensures brokers have sufficient
advance notice to make the time,
resource, and training investments
to participate in exchange for
upcoming year
• Current industry practice
provides minimal advanced
notice
• Would require insurers to
finalize decisions earlier
Exchange Authority | 40
▪ Summary of Stakeholder Feedback:
▪ General support from stakeholders (assisters, brokers, consumer groups).
▪ Brokers reported that currently they receive minimal to no advanced notice (as little as 5 days) which makes it difficult for
them to plan for and prepare for participation on exchange. Simply knowing commission schedules further in advance
would be helpful.
▪ 5 of 7 Insurers supported, with some requesting modifications to the proposed 90 day timeframe and exceptions for late
plan filing changes with PID
▪ Opposition from 2 Insurers who expressed concerns including “can potentially hurt competition between insurers and between
brokers”, “potential to equalize and stabilize commissions above what would otherwise be competitive levels with resulting price
increases”, and concern about ability to change commissions later in the year.
▪ Staff Recommendation: Amend Requirement #4 to change timeframe to at least 45 days in
advance of OEP. Add mid-year changes to be reported at least 30 days in advance. Add
exceptions for extenuating circumstances.
▪ We understand the concerns about the timeframe and support modifying it. We will monitor this in year 1 to see if timeframe
works well for both insurers and brokers. Added clarification about mid-year changes, assuming Requirement #3 is not finalized.
2021 Plan Certification
Proposed Requirement #4
Proposal Policy Goal(s) Benefits Challenges
Meaningful
Difference
Provide high quality,
affordable,
comprehensive health
coverage to
Commonwealth residents
• Ensure plans provide added
value to the customers of
differentiated features, and
sufficient but not
overwhelming choice
• Can be difficult standard to
quantify
Exchange Authority | 41
▪ Summary of Stakeholder Feedback:
▪ Broad support across consumer groups, brokers, assisters, insurers, providers/health systems.
▪ Support for plenty of choice but understanding that too much choice is overwhelming to customers
▪ Several Insurers sought clarification, including requesting examples of what would pass/fail the reasonable consumer
standard, request that the federal definition and standard be applied for year 1, and recommendation that an easier path
be found for comparing differences in an insurer’s plan networks.
▪ Staff Recommendation: Adopt consideration #1, as written
▪ Staff will provide examples to insurers to provide clarity.
2021 Plan Certification
Proposed Consideration #1
Proposal Policy Goal(s) Benefits Challenges
Avoid Disruption due
to Renewal Plan
Mapping
Seamless autorenewals
for customers into
appropriate comparable
plans
• Ensure customers are
autorenewed into the
most appropriate
comparable plan without
surprises of significant
changes
• Limited time to develop a new plan
mapping standard for 2021 which can be
complex
Exchange Authority | 42
▪ Summary of Stakeholder Feedback:
▪ Broad support across consumer groups, brokers, assisters, providers/health systems, and half of insurers.
▪ Support for trying to most appropriately identify comparable plans from year to year in support of autorenewal, without surprising
customers with significant changes that they might not be aware of until after close of OEP.
▪ 1 Insurer sought clarification on the types of changes that would qualify as “significant disruption”, and recommended that changes
made to plans solely to meeting AV calculator requirements should not be treated as disruptive.
▪ Half of insurers expressed concerns including:
▪ Request to use the FFM standard in 45 CFR 155.335(j) for 2021, and work with stakeholders to develop a PA-specific policy in the
future if appropriate;
▪ Concern that plan mapping should not be part of QHP certification, and suggested that any disruption due to plan mapping should be
handled by notices and customer communications.
▪ Staff Recommendation: Amend to recommend using FFM standard for 2021.
▪ We intend to monitor this issue in 2021 to better understand the extent to which this is an issue impacting Commonwealth
customers, and raise for reconsideration in future years as appropriate.
2021 Plan Certification
Proposed Consideration #2
Proposal Policy Goal(s) Benefits Challenges
Effect on APTC Ensure Pennsylvanians
have continuous access
to high-quality
affordable health plans
• Prevent APTC devaluing
ensures continued
affordability for financial
assistance customers
(88% of marketplace)
• APTC devaluing can occur naturally due
to other factors that we would not want
to stop, including new entrants to the
marketplace, or new products competing
against other insurer products
Exchange Authority | 43
▪ Summary of Stakeholder Feedback:
▪ Stakeholder feedback was mixed. In general, broad group of stakeholders supported the intent of the policy to ensure continued
affordability by avoiding unnecessarily devaluing APTC, however they found the topic complex and challenging.
▪ Half of insurers supported, half said they did not support either because they were concerned it would prohibit competition amongst
other insurers or because there were unsure what actions would be permissible and which would not be under this consideration.
▪ Staff Recommendation: Amend consideration #3 to clarify intent (not to stifle competition), & require
Board approval before taking action based on this consideration
▪ It is very unlikely that this policy lever will ever be pulled as it is only be necessary to protect consumers from pricing strategies
which prioritize market share specifically at the expense of net premium after APTC for all subsidized customers (one known
example in the history of exchanges). APTC value will fluctuate year over year, and in the event it goes down due to price
competition (e.g. new insurer in marketplace, insurers introducing new lower cost products to compete with one another), no action
would be warranted.
▪ Given the potential severity of impact on affordability, we strongly support keeping this consideration available as a tool, but
recommend amending to clarify that this is not intended to stifle competition and to require Board approval to take action based on
this consideration.
2021 Plan Certification
Proposed Consideration #3
2021 Plan Certification Public Comment and Board Discussion
Exchange Authority | 44
Pennsylvania Health Insurance Exchange Authority
Notice of Benefit and Payment Parameters
45
▪ What is the NBPP?
▪ Annual federal rule issuing guidance or clarification of previously issued guidance on a variety of ACA programs, including Exchanges.
▪ Draft rule issued 1/31/2020, Public comments due 3/2/2020
▪ Some of the proposed guidance would directly impact the state-based exchange (SBE), or they have requested comment on whether the proposed guidance should be applicable to SBEs
▪ We propose commenting on a few Exchange-specific policies
▪ General comments about need for state flexibility
▪ Special Enrollment Period (SEP) changes
▪ Change to APTC on certain autorenewals
Note: We will not be commenting on parts of the federal rule that are under PID’s purview.
Draft 2021 Notice of Benefit & Payment Parameters (NBPP)
Exchange Authority | 46
1. State Flexibility
▪ Advocate for state flexibility to implement (or not) any proposed regulatory changes in a
manner consistent with enabling statute and in the best interest of the Commonwealth
and its residents
2. Special Enrollment Periods (SEP)
▪ Support for proposed regulatory changes that increase customer flexibility to use SEPs to
enroll in coverage
▪ Concern regarding changes that would restrict a customer's ability to make an informed
decision about their coverage and when it is effectuated
NBPP
Summary of Comments
Exchange Authority | 47
3. Proposed elimination of APTC for autorenewals where customer has no cost
premiums
▪ Proposed FFM rule for 2021, requesting comment on whether to require SBEs to implement as well
▪ Renewal Scenario:
▪ Customer is renewed into an auto-renewal policy
▪ Customer’s APTC amount is >= premium
▪ Result to customer is $0 premium for auto-renewal policy
▪ Current Policy:
▪ If no action during OEP, enrolled in auto-renewal policy with full APTC and zero dollar premium.
▪ Proposed Policy:
▪ Customer would be auto-renewed but NO APTC would be applied.
▪ If no action during OEP, customer auto-renewed and responsible for FULL premium.
▪ In order to receive APTC, customer would need to:
▪ Complete a new eligibility application
▪ Make an active plan selection to apply the APTC
Exchange Authority | 48
Draft 2021 NBPP
Summary of Comments
Decision Policy Goal(s) Benefits Challenges
Remove APTC from
Auto-Renewal if Zero
Dollar Premium?
Proposed federal rule,
reduce eligibility errors
& potential government
misspending
• Per rule, protects against
incorrect APTC
expenditures, some of
which cannot be
recovered through
reconciliation process
due to caps
• Scope of the purported issue unclear
• Would create additional barriers to
coverage for customers with greatest
need for assistance
• Change to customer expectations &
understanding of annual renewals
• Technical work to implement
Exchange Authority | 49
NBPP (stakeholder feedback)
▪ Summary of Stakeholder Feedback:
▪ Broad opposition to this policy across all stakeholders (consumer groups, brokers, insurers,
providers/health systems, assisters)
▪ Concern that this would negatively impact the most vulnerable population, create unnecessary
barriers to coverage, and fundamentally change how OEP has worked for the past seven years
leading to customer confusion.
▪ All stakeholders expected this to lead to an increase in uninsured population
▪ Staff Recommendation:
▪ Advocate that this policy adversely impacts vulnerable populations and would increase uninsured
population, and reiterate need for states’ rights to make decisions right for their unique market.
APTC and Auto-Renewals
Pennsylvania Health Insurance Exchange Authority
Review of Proposed Employee Handbook
50
Why create an Employee Handbook?
▪ Human Resource (HR) policies and procedures are necessary to have a successful workplace.
▪ Statutorily, as a state-affiliated agency, we are not directly subjected to the same policies and
procedures as the agencies under the Governor’s jurisdiction.
▪ As a result, the Exchange Authority needs to create its own HR policies and procedures.
What we did
HR, in conjunction with the Office of Chief Counsel, drafted the proposed Employee Handbook.
We remained consistent with the agencies under the Governor’s jurisdiction to the extent possible.
Employee Handbook
Exchange Authority | 51
Special Holidays (Page 9)
▪ Traditionally, a Secretary does not have the ability to call a special holiday, only the Governor (or independent agency head) can.
▪ An example of this was the decision of Governor Wolf to close the agencies under his jurisdiction during the funeral of President Bush.
▪ This policy would give the Executive Director the ability to a) call a special holiday when the Governor does; and 2) create a special holiday for reasons specific to the Exchange Authority, if necessary.
Extraordinary Pay Increases and Bonuses (Page 11)
▪ The ability to issue Extraordinary Pay Increases is consistent with the agencies under the Governor’s Jurisdiction. These are pay increases above what is deemed as the agency-wide cost of living adjustment and are for exceptional service to the Commonwealth.
▪ The ability to issue bonuses is not unheard of in state government, but it is rare. Unlike an Extraordinary Pay Increase – which would change the level of pay an employee receives – this would be a onetime cash payment for quality work performance.
Employee Handbook
Exchange Authority | 52
Recommended Motion: To adopt Version 1.0 of the Exchange Authority’s Employee Handbook,
dated February 19, 2020, as the employee handbook of the Pennsylvania Health Insurance
Exchange Authority.
Employee Handbook
Sections to Note
Exchange Authority | 53
Pennsylvania Health Insurance Exchange Authority
Adjourn
54